Under KKDIK, companies registering the same substance submit a joint dossier led by a Lead Registrant. This role largely determines the speed and quality of the registration.
The Lead Registrant compiles the shared data set, classification and, where required, the Chemical Safety Report on behalf of the MBDF; coordinates testing and data gathering; and submits the joint registration via KKS. Member registrants add their own tonnage and use information.
ONAY Mühendislik acts as Lead Registrant for many substances, offering independent technical dossier development and digital MBDF infrastructure.
Related pages
Contact ONAY Mühendislik for KKDIK and REACH compliance support.
Yönetmeliğin resmî tam metni: KKDİK Yönetmeliği — Resmî Gazete.
What the lead registrant actually does
The lead registrant assembles the joint data set, prepares the technical dossier and submits it first. Members then join that submission through a letter of access. In practice the role is part technical work and part secretariat: collecting analytical data, tracking who has paid and answering questions from the authority.
How the role is agreed
Members choose the lead by consensus. The company with the largest tonnage and the best access to existing studies usually takes it, but organisational capacity matters just as much. A lead that cannot keep the process moving delays every other member and pushes the whole forum towards the deadline.
What members should insist on
Members are entitled to a transparent cost breakdown and should pay only for the data their own tonnage band requires. Ask for the study list, the price per band and the refund mechanism in writing before signing anything.
What happens if the lead withdraws
If the lead registrant leaves the market or stops meeting its obligations, the forum appoints a replacement. Data rights and the archive must transfer in writing, otherwise members who already paid can lose access to studies they funded. Agreeing this at the start costs nothing.
Being a member is not passive
Members still confirm sameness for their own material, check that their uses are covered and keep their own evidence file. Relying entirely on the lead is the most common reason a member discovers, during an inspection, that its registration does not describe its actual activity.